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Update - U.S. IRS Publishes Agreement with Bulgaria on Exchange of CbC Reports

10 June 2024

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Treaty Development

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United States-Bulgaria

The U.S. IRS has published the agreement (IGA) signed with Bulgaria on the exchange of Country-by-Country (CbC) reports. The agreement was signed on 30 May 2024 and the operative date is to be determined. The IGA provides that Pursuant to the provisions of Article 25 of the 2007 Bulgaria-U.S. tax treaty, the Competent Authority of each Party shall exchange CbC Reports with the Competent Authority of the other Party annually on an automatic basis. For this purpose, it is also provided that the two countries will sign a competent authority arrangement (CAA) that provides the specific details for the exchange...